MEL Rectification Interval expiry

[Rhadamanthys]

Colleagues
I have a question with respect to the expiry of rectification intervals defined in MMEL / MEL. I have searched all available regulating documentation without finding the answer.
Allow me to elaborate my query. Lets take an example of a MEL category A that has an RI of 2 days.

Lets say the fault was discovered on the 1st Jan, 2008 at 16:30, 1st of Jan will be the day of discovery & the count for the rectification interval will begin at 00:00 2nd Jan & expire at 23:59 3rd of Jan

My question is as follows: With no rectification carried out on the 2nd or the 3rd, is a flight programmed to depart at 23:30 3rd of Jan legal? The idea obviously being that the MEL is cleared when the A/C arrives at the maintenance base at 07:00 on the 4th....

My personal thoughts are that this flight cannot be programmed because the MEL expires inflight & should be taken into consideration during dispatch. All I have found supporting my theory is a document that Airbus published to aid operators in understanding concepts used in the MMEL/MEL. Below is the link (see page 40)

http://www.flightlevel400.com/docume...dMEL220705.pdf (http://www.flightlevel400.com/document_files/grips/GettingToGripsWithMMELandMEL220705.pdf)

The thing is I havent been able to find any regulatory documentation describing or clarifying this concept

I would like to know the communities' thoughts on this & if anyone knows where I may be able to find official documentation that clarifies this issue.....

Thanks

[swiss_swiss]

using your example then i say no it is not legal as the AC will be flying with a defect outside of the MEL time frame...... it also depends on the companies MOE/MPM and wether the mel can be extended - but TBH if its a mel A item i doubt it.

[Fargoo]

No problem in the flight being scheduled but it should not depart until that defect is rectified.
As soon as the MEL limit expires the aircraft no longer remains airworthy.

From JAR OPS

b) An Operator shall not operate an Aeroplane
other than in accordance with the MMEL unless
permitted by the Authority. Any such permission
will in no circumstances permit operation outside
the constraints of the MMEL

[Nightrider]

This actually depends on the procedure your company has lead down in the MEL and which is required to be approved by the respective DGAC / CAA.

Inside JAR it is possible that you have the option to have the Tech. Director to approve an extension for the very same period as the MEL originally limited the item; i.e. in your case, the Technical Director may approve to operate with the deferred rectification until 5th January 23:59
Other operators (due to authorities) need prior approval from the respective CAA to defer the rectification for the same period or shorter, as case may be decided.

In both scenarios the extension has to be mentioned and signed by an authorized engineer near the entry in the ADD listing.

In any case, the aircraft is not allowed to be dispatched nor operated outside the approved and signed deferred rectification period.

[Fr8Mech]

From this end of the Pond, and wih my operator, it is legal to operate that flight. So long as the aircraft departs before midnight EST or EDT, as applicable, the aircraft can operate. Of course, it dies at its destination, even if it diverts for some reason.

I'll look for the pertinent regulation or document and post the reference if it is FAA, after I get some sleep. It's daytime here.:)

[mafibacon]

This is an extract from a CAP 549 (2003) dealing with the construction of an MEL.
"5 Rectification Intervals
Inoperative items or components, deferred in accordance with the MEL, must be
rectified at or prior to the Rectification Intervals established by the following letter
designators given in the " Rectification Interval Category " column of the MEL.
Category A
No standard interval is specified, however, items in this category shall be rectified in
accordance with the conditions stated in the remarks column (5) of the MEL.
Where a time period is specified in calendar days or flight days, the period shall start
at 00:01 on the calendar day following the day of discovery.
Category B
Items in this category shall be rectified within three (3) consecutive calendar days,
excluding the day of discovery.
Category C
Items in this category shall be rectified within ten (10) consecutive calendar days,
excluding the day of discovery.
Category D
Items in this category shall be rectified within one hundred and twenty (120)
consecutive calendar days, excluding the day of discovery.
Rectification Interval Extensions (RIEs)
Subject to the approval of the CAA, the operator may use a procedure for the
extension of the applicable Rectification Intervals B, C and D, for the same duration
as specified in the MEL in accordance with CAP 549."
I feel sure it has been revised since then. But at the time I wrote a CAME for a regional airline and had the RIE procedure accepted for the airline. I may have a copy at home - I will check after work.
Hope this helps
MB


`
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[Vortechs Jenerator]

Basically all you're asking the is if ALL maintenance action items require to be valid at T/O only or flight duration and Landing.

This must stand for OOP's, Daily, ADD's, concessions etc.

I was always under the impression that the C of A required all items to be serviceable with enough time remaining to complete the entire flight.

JAR-OPs should cover this.... I'm off for a look

[Rhadamanthys]

Thanks for your input guys
Its strange that at some airlines this concept is considered acceptable & is common practice (the airline I work at included)
My understanding in this regard has always been that it is not OK to release an aircraft in this condition

1- An aircraft cannot commence a flight without a valid maintenance release covering the entire period of the proposed flight, certifying that all required maintenance as been carried out & certified on the aircraft
2- The maintenance release must also consider permissable unserviceabilities (MELs) and previous maintenance releases

Unless I'm mistaken in my understanding of this concept, the flight that I mention is illegal

I took this up with our Quality manager & even he thinks that as long as the flight takes off before midnight, its legal. From what he explains, European regulations are more strict & the FAA regulations allow you to make that last flight. I havent been able to find any documentation however that clarifies this

Cheers

[Rhadamanthys]

OK I see mixed reactions to this post

I got a followup question for Fr8Mech & ASFKAP
We all agree that even though the rectification interval for MEL is in days, the issue I'm talking about comes to the last moments before expiration hence we're looking at it from an hours standpoint

Lets take the case of a 400H check. The Aircraft is at a station 8 hours away from the base & at 398 hours. Using the same logic shouldnt I be able to bring the A/C back to base & execute the check upon arrival??

[Engineer]

In your original example you did not specify what CAT A time frame is used.

As an example for an FDR fault the MEL will state a limitation on the time say 3 flight days This means if the aircraft remains on the ground for a week, you could then operates the aircraft every other day in this case the MEL entry would be valid for 13 days You can use any combination you want but the bottom line is that limitation is based on flight days

However if the MEL stipulates 6 calender days then at the end of this period it must be fixed or a concession obtained.

It is only applicable to CAT A item because all other categories are based on calender days only

Regarding service checks the rules are black and white on this if a check will expire in flight the check must be done before it takes to the air unless you obtain an extension to the check such that it expire on the ground

[Rhadamanthys]

Actually I only used Cat A in the example so people wouldnt bring RIE (extensions) etc into the picture

And youre mistaken about the Cat A being restricted to Flight Days. While the Cat A doesnt have a defined RI unlike the other categories, it can be Flight Days, Calender Days, Flight Cycles or even Flight Hours, The major distinction (other than the fact its variable) is that it cannot be extended (RIEs donot apply to Cat A MELs) - neither JAA nor FAA allows this

Independently though, my point was specific to the final moments before expiration (considering the count - be it flight day or calender day has already begun & is about to expire)

[mafibacon]

The situation you describe should be covered in the Pre amble to the MEL.
Additionally the OPs Manual will give you the answer - or should do!
From my experience in compiling both MELS and CAMES for a number of operators, the effective day of an MEL item commences at mid night on the day it was discovered and terminates at midnight on the last day of permitted operation. If your organisation has an approved RIE procedure then an extension of the original RI would/could be granted by the agreed signatory to the RIE, normally a senior Pilot, i.e.Fleet captain.
MB

[Rhadamanthys]

What I mention here is not stipulated neither in Ops manual, nor in regulation documentation. All that is explained is how the RI is calculated Calender day, like you say midnight following day of discovery etc.....

& like i mentioned, RIE's donot apply to MEL As

[Engineer]

Operation of the aircraft is not allowed after expiry of the Rectification Interval
specified in the MEL, unless:
a) the defect has been rectified; or
b) the Rectification Interval is extended in accordance with paragraph 8 below
Extract from CAP 549 Para 7.3

Same statement in JAR-MMEL/MEL.080 (c)

So like the service check mentioned earlier same procedure applies

[mafibacon]

Just recieved the latest rev to the B767 (Rev5) CAA MEL Supplement and copied this from the Pre-Amble.
It should close the 'start/finish' question of an MEL item, and is as stated earlier.
The Note at the end shows the RIE extension conditions, i.e the operator must have an approved system in place to operate an RIE procedure.
`
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""Rectification Interval" (Column 2) : Inoperative items or components, deferred in accordance with theMEL, must be rectified at or prior to the rectification intervals established by the following letter designators given in the "Rectification Interval" column (2) of the MMEL.
`
Category A
No standard interval is specified, however, items in this category shall be rectified in accordance with the conditions stated in the Remarks column (5) of the MMEL.
Where a time period is specified it shall start at 00:01 on the calendar day following the day of discovery.
Category B
Items in this category shall be rectified within three (3) consecutive calendar days, excluding the day of discovery.
For example, if it was recorded at 10 am on January 26th, the three day interval would begin at midnight on the 26th and end at midnight on the 29th[I].
Category C
Items in this category shall be rectified within ten (10) consecutive calendar days, excluding the day of discovery. For example, if it was recorded at 10 am on January 26th, the 10 day interval would begin at midnight on the 26th and end at midnight on February 5th.
Category D
Items in this category shall be rectified within one hundred and twenty (120) consecutive calendar
days, excluding the day of discovery.
Note: The operator may permit, with Authority agreement, a one-off extension to the applicable rectification interval B, C or D for the same duration as that specified in the MMEL, in accordance with JAR MMEL/MEL.[
/I]Cheers
MB

[ahramin]

In North America MELs are dispatch documents. As long as the plane is airborne before the time specified you are good to go.

[Fr8Mech]

MEL time restrictions and calendar day/hour restrictions for checks are different. Our MEL procedures allow for departure up to midnight of the expiration date. Our lowest level check above the daily allows the same. As far as I know, evey other check must arrive before the drop dead time/day.

[Min W]

Hi friends, I have question. My fellow mechanic raise interesting question. As per discussed in this session, everybody understand that the MEL time clocking starts at 0:00 of the next day of the "discoverty".
My question is:
Q1) If defect is found in c-check, and it was impossible to rectify the defect, the starting potint of the MEL should be the next day of A/C RTS signed-off?
Q2) Or should the starting point still be next day of the discovery?
Q3) Some of my colleague suggested MEL is originally intended for the use of operation (not for maintenance) and applying MEL meant degrade of the system redundancy, so, it is normal to have the attitude to fix such defect until dock-out. Yes, but if the parts not arrived and need to A/C back to base, what's happen?


If any regulatory guide line exists for such scenario, please let me know (if you can post the web link, it is very happy).

[BCAR Section L]

I don't understand any of this discussion. Safety first full stop. The answer to the main question is that the aircraft must arrive airworthy in terms of known defects and scheduled items.

Why allow yourself to be compromised?
Please read and understand the dirty dozen especially the one about assertiveness.

[tuned cavity]

BCAR you appear to have got the wrong end of the stick. MEL reliefs are used to allow an aircraft to continue in service with a defect. The MEL is not a maintenance document it is a FLT OP's controlled document and agreed with the Authority. For this reason the Deferred Defect Record is examined by the FLT CREW and may depart a station with an active MEL relief provided it has not expired. Should it expire in flight it may continue but cannot depart again as the aircraft is no longer serviceable unless the MEL relief is extended or cleared.

[Rigga]

Nice one TC.

[BCAR Section L]

Too many seem to have been cheating for so long they are unaware of which way is up and which way is down.

An aircraft must LAND AIRWORTHY with regards known defects and scheduled maintenance. Landing 6 hours after an MEL item has expired means the aircraft flew in a known unairworthy condition. Just as departing for a 6 hour flight knowing the next c check is 2 hours away is too.

That was the origin of the maintenance statement and you may not depart on a sector unless there is sufficient time remaining.

The MEL process is to enable continued operation with unscheduled defects. The preamble also makes it clear that the defects should still be dealt with asap regardless of any given time frames. Trying to justify that an aircraft is ok to fly when an MEL item expires during flight highlights there are still too many gangsters in the business.

There should be processes in place to ensure this doesn't happen should there be a lack of spares or particularly difficult troubleshooting. Overruns are also possible.

Departing knowing an item expires in flight is not an available option.

[tuned cavity]

BCAR, please accept my apology. I have checked again the FAA MMEL preamble and you are correct. The aircraft cannot be dispatched onto a sector which will terminate after 2400hrs on the last day of the relief.



From FAA MMEL Definitions.
Category A. Items in this category shall be repaired within the time interval specified in the remarks column of the operator's approved MEL. For time intervals specified in “calendar days” or "flight days," the day the malfunction was recorded in the aircraft maintenance record/logbook is excluded. For all other time intervals (flights, flight legs, cycles, hours, etc), repair tracking begins at the point when the malfunction is deferred in accordance with the operator's approved MEL.

Category B. Items in this category shall be repaired within three (3) consecutive calendar days (72 hours), excluding the day the malfunction was recorded in the aircraft maintenance record/logbook. For example, if it were recorded at 10 a.m. on January 26th, the three day interval would begin at midnight the 26th and end at midnight the 29th.

I guess we require a MEL revision.
TC

[Min W]

Dear BCAR and TC,


Thank you for your advice. Of course, we know all the defect should be rectified during C-check and that's a common attitude. But when A/C is dock-out, and one system is faulty among two system, and pilot came to the dock for ferry flight and he agreed to apply MEL, is it possible to release the ship? Again, we will pay every effort to fix the failure and this is a kind of scinario we've never experienced before. If any other operator had this scinario before, we would like to know how they (you) deal with this situation. Or I am wondering if there is a special clausure in your own MEL approved by your local authority? If anybody have some interpretation and/or regulatory opinion/comment document for this kind of situation. could you please help and make my thinking clearler? My apology in advance for bothering you....

[Jet II]

Its not unusual for defects not to be fixed on C check to go back into service covered by a deferral. What happens a lot of the time is that if a check aircraft needs an Air Data Module for example and there are no spares available it will be deferred under MEL and when the aircraft gets back on the ramp an ADM will be robbed from the next aircraft to go on C Check.

[Min W]

So what is the conclusion? When we have dock maintenance (c-check), but at the very end of the duration, fault of a system was revealed. In the scinario, can we apply MEL to make A/C back to base? Should we consider the start point (date of finding) as a RTS sign-off date of the C-check? Any consultation is happy for me. Moreover, I wish to know if there is a publicated guidance for such scenario....:zzz: